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The SEC's Proposed Pay Ratio Disclosure Requirements: Another Fine Mess

Among the many measures Congress included when it enacted the sweeping Dodd-Frank Act in 2010 was a provision directing the SEC to require companies to disclose the ratio of CEO compensation to median employee compensation. The statutory provision, incorporated into Section 953(b) of the Act, reflected...

SEC Independence: The Political Process, Rule Making and The Courts

In three recent addresses SEC Chair Mary Jo White has given definition to her vision for the agency. In one, she discussed Enforcement policy ( here ). A second focused on market structure ( here ). In a third, titled The Importance of Independence, delivered to the 14 th Annual A.A. Summer, Jr. Corporate...

SEC Enjoined For Failing to Timely Issue Mineral Disclosure Rule

The Dodd-Frank Wall Street Reform Act imposed a requirement on the SEC in Section 1504 to promulgate a disclosure rule regarding certain extraction payments involving resource issuers within 270 days of passage or by April 17, 2011. The history of the Commission’s efforts in this area is riddled...